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for institutional change. The following comments relate to

H.R.3964:

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A National Park System Review Board has merit. However, a full time entity with the level of proposed staffing would severely undermine the leadership of a qualified directorate. A larger body, advisory in nature and consisting of perhaps 9 to 11 qualified citizens, should be considered. It would advise the Congress, the President and others on many of the same items noted in Sec. 1 (a). It could help identify the National Park Service's budget and long term resource needs.

O The proposed qualifications of both the Board and Director omit other qualified persons. The proposed qualifications would likely eliminate from service the type of person historically involved in the past who have been among the most creative directors. Further, restricting consideration to persons with experiences with "natural and cultural resources" likely would eliminate from consideration a person whose education and strengths are focused on recreation management. The "people" impacts on the System are increasingly severe and well-documented. Probably the most effective Board and Directorate would be heavily represented by demographers, sociologists and recreation managers, supported by qualified specialists in the physical sciences, history and so on.

O The relationship between the National Park Service, other Interior department bureaus and non-Interior departments and bureaus would be confused.

The National Park System does not exist in a federal vacuum. Since its inception the System has had both negative and positive influences as a result, say, of the Bureau of Land Management, Fish and Wildlife Service, Forest Service and others. All of these agencies protect resources and make them available for recreation. Absent full cabinet level interest in and representation of the National Park Service we envision a continuing state of uncertainty and unproductive relationships.

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The proposed budget process is unclear. In the long term we believe that involvement by higher authorities in the NPS budget process is useful. The proposed process leaves unanswered whether the proposed authority is permissive only, whether a NPS budget would literally be independent of an administration's government-wide budget request, and how a President might respond after the Congress took action on an independent budget.

The President's Commission of Americans Outdoors and a large coalition of national private groups have also addressed the issue of government structure for parks and recreation. PCAO recommended an independent "institution

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We support the arguments for the strongest possible organization to manage the National Park System.

We

Concurrently, we believe the National Park Service should not be encumbered with a wide range of delegated authority and functions which intrude on its basic management mission. urge this Subcommittee, perhaps along with others, to consider fully other structural responses to address the Nation's ongoing and long-term recreation and park needs.

Several organizations have discussed the needs and

merits of a national institutional focal point in government for parks and recreation. The institution we envision would have no direct resource management functions. Its principal focus would be to encourage and aid public awareness of recreation and recreation resource values; to discover and leverage public recreation opportunity from numerous existing and future national policies and programs; and to encourage other public institutions, governments and private interests to consider recreation needs and to invest

appropriately.

Much of the anticipated activity is

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authorized by existing laws.

However, new authority is

necessary to deal with institutional matters.

Organizationally, perhaps four existing National Park Service divisions and a limited number of NPS regional staff would be directly involved. The institution and functions proposed here parallel a proposal on existing and future

An outline of the

historic preservation law and functions. potential goals and functions, as envisioned by ourselves and others, is attached to this statement.

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We believe this is a far reaching proposal. It has the potential to bring the United States government back in to the mainstream of public attitudes about recreation and parks. Among these views: That recreation should be an element of and enhanced by many policies and actions health, housing, agriculture, transportation, and many others; that we must be equally knowledgeable about the human dimension as we are about physical resources; and that we must look to a full range of mutually necessary and desirable partnerships to protect resources and meet recreation demands.

We have no illusions that the Congress will immediately adopt this idea. Thus, in the interim the Subcommittee might consider the following proposals:

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A. Create in Interior an 'Administration for Parks and

Recreation.' Three 'directors' would respectively be

responsible for the National Park System; Recreation Policy, and Historic Preservation.

B. Create in the National Park Service three deputy directors, with responsibility for the areas noted above.

Of these alternatives proposal "A" would, in our view, be preferred and could be considered depending on further structure as a substitute for the proposed independent endowments.

The Subcommittee has initiated a discussion on a topic with broad implications. We commend you for it, and look forward to continuing the dialogue.

I would be pleased to respond to questions.

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